Peter T. Storaasli - Page 5

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          family residence that petitioner remodeled and converted into               
          office space.5  In January 1996, petitioner sold the property for           
          $212,500.                                                                   
               Respondent added $1,671 for acquisition costs and $41,743,             
          the cost of capital improvements,6 to petitioner’s cost basis in            
          the Market Street property.  In computing the amount realized on            
          the sale, respondent subtracted $4,373 from the sale price to               
          account for selling costs.  Using an adjusted sale price of                 
          $208,127 and an adjusted basis of $186,914, respondent concluded            
          that petitioner must recognize gain of $21,213 on the sale of the           
          Market Street property.                                                     
               Respondent did not include any of the following expenses,              
          which petitioner claims should increase the Market Street                   
          property’s adjusted basis, in computing petitioner’s gain:                  









               5Petitioner testified that he used the office space to                 
          conduct his business of importing shoes and leather goods and               
          that he never resided at the Market Street property.                        
               6Petitioner originally claimed in his petition an amount of            
          $62,500 for capital improvements, but he maintained in his trial            
          memorandum and at trial that he incurred expenses of $47,500 to             
          improve the Market Street property.  We assume, therefore, that             
          petitioner has waived any argument regarding the difference                 
          between the two figures.                                                    





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